8. Create regulations that encourage the disparity of clinical data.

Data, data, everyone wants data. It is hard to keep track of all the Health Care Data people want. CMS wants good billing data to make sure they are only paying for the services that they contracted to pay and only for those patients who really need it. They also want to make sure that basic treatment protocols are followed to insure that patients get proper care so they developed a Pay for Performance under the alphabet soup of PQRI to provide incentive to physicians who report treating certain diagnostic clusters in a predefined manner. Commercial payers want to make sure they are only paying for services which they are contracted to pay (not necessarily the same as CMS) and only when they need to. In addition, they too are beginning to develop their own Pay for Performance based programs and as one has come to expect their measures are not the same as CMS’s measures. Patients would like their own data so that they can review it and make sure it is correct and control where it goes.

I work in the area of Cardiology and the following is what is before us. The American College of Cardiology has an IC3 quality improvement program and they would like to set up an outpatient registry for cardiology patients to improve overall all quality by data analysis. ACC has a certification program that requires vendors to ask specific questions in the EMR, provide specific answers to those questions, and require specific methods for extracting that data on a regular basis and send it to them. The American Heart Association has also recently proposed a set of data standards that they would like cardiologists to follow which is approved by a national quality initiative program called NCQA. CMS (Medicare as mentioned earlier) has the PQRI program that pays providers 2% more than the fee schedule to participate. You must remember though that this 2% increase is on top of whatever decrease they decide to give providers. Third party payers have created their own unique quality program that will either be based on an incentive plan such as CMS or a disincentive plan (you get your fees reduced). States are getting into the act and some of them provide report cards on providers and practices based on data they require from the providers. The provider is being asked to spend his (or his staff time) time providing specific data to specific groups on specific topics at his own expense. Everyone has a stake in this data, and no one can agree on one set of standards. They do however, agree that provider should bear the financial burden to provide the data. It is no wonder that even if a provider wants to purchase an EMR he resents it because more often then not it will be used to benefit all these other groups that he sees as doing nothing but making his practice of medicine more difficult while reducing his fees to do so.

Providers end up seeing these initiatives as either barriers to care and financially costly or they see them as a way to get some of their income back. Those initiatives that provide an incentive they jump on, right? Wrong. When provided an incentive to do this extra work, only 25% of our network participated in it even though we built a module for them to do it and provided it to them at no additional cost above their support payments. Why? Because they are tired of doing more work and as one physician stated, “The amount of time this takes me I could see two more patients a day. If I see two more patients per day I make significantly more than 2%.” The bottom line is I don’t see this improving care or encouraging EMR’s. If you want EMR adoption, than pay an incentive for owning one. Once you have people on it, you can move to improving quality.